2025 (4) TMI 616 - SCH - Income Tax

Reopening of assessment u/s 147 - reasons to believe - notice u/s 148A(b) - whether information disclosed vide notice under Section 148A(b) of the IT Act is not covered by the information specified in Explanation 1(i) of Section 148 of the IT Act? - as decided by HC 2024 (1) TMI 368 - RAJASTHAN HIGH COURT Jurisdictional Authority along with notice dated 13.3.2023 u/s 148A(b) of the IT Act has supplied information available with it with the documents such as insight portal wherein information/description has been given. In the notice dated 13.3.2023 under Section 148A(b) and the order dated 28.3.2023 u/s 148A(d) of the IT Act issued by the Assessing Officer it is clearly mentioned that in the insight portal the case of the petitioner is flagged on High Risk CRIU/RU PAN Case for the relevant assessment year. Case of the petitioner is covered by information specified in Explanation 1(i) of Section 148 of the IT Act. HELD THAT - It is brought to our notice that Assessment order has already been passed on 26.03.2024. Petitioner(s) also submits that the appeal against the said order(s) has been filed and is pending consideration before the Appellate Authority. In this view of the matter there is no reason for us to interfere with the order(s) impugned. The Special Leave Petitions are dismissed.

Summary

**Summary:**In the Supreme Court judgment, Justices Pamidighantam Sri Narasimha and Joymalya Bagchi presided over the case. The petitioner was represented by Mr. Prateek Gattani and others, while the respondent's counsel included Mr. N Venkatraman, A.S.G., and others. The Court noted that an assessment order had been issued on March 26, 2024. The petitioner's counsel informed the Court that an appeal against this order is currently pending before the Appellate Authority. Consequently, the Court found no grounds to interfere with the impugned order, resulting in the dismissal of the Special Leave Petitions. All pending applications related to the case were also disposed of.